An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents NHS Trust An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Version: Ratified by: Date ratified: Name of originator/author: Name of responsible committee/individual: Name of executive lead: Date issued: Review date: Target audience: V.5 March 2012 Page 1 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Contents 1 Introduction ............................................................................................................. 5 2 Purpose .................................................................................................................... 5 3 Explanation of Terms ............................................................................................... 5 4 Duties ....................................................................................................................... 8 4.1 4.2 5 Duties within the Organisation ............................................................................................... 8 Committees and Groups with Overarching Responsibilities .................................................. 9 Response, Communication and Notification ......................................................... 10 5.1 5.2 5.3 5.4 5.5 6 Immediate Response by the Organisation ............................................................................ 10 Reporting the Incident .......................................................................................................... 10 Patient/Relative/Visitor/Contractor Communication and Support ...................................... 11 Internal Communication ....................................................................................................... 11 External Stakeholder Notification ......................................................................................... 11 Communication with Staff ..................................................................................... 12 6.1 6.2 7 Communication Following an Incident ................................................................................. 12 Process by which to Raise Concerns ..................................................................................... 12 Media Involvement ................................................................................................ 12 7.1 7.2 7.3 Media Unaware of Serious Incident ..................................................................................... 13 Media Unaware but Proactive Media Handling Necessary .................................................. 14 Media Aware of Serious Incident .......................................................................................... 14 8 Hotline Arrangements ........................................................................................... 14 9 Incident Investigation ............................................................................................ 15 9.1 9.2 9.3 9.4 9.5 9.6 9.7 9.8 9.9 9.10 9.11 Incident Grading and Appropriate Levels of Investigations .................................................. 15 Responsibility for Investigation............................................................................................. 15 Responsibility for Causal Factor Analysis .............................................................................. 16 Responsibility for Causal Factor Analysis Post Investigation ................................................ 16 Involving Patients and their Families in Investigations into Serious Incidents ..................... 16 Involvement of Relevant Stakeholders ................................................................................. 16 Root Cause Analysis (RCA) and Investigation Report............................................................ 17 Recommendations and Action Planning ............................................................................... 17 Monitoring of Action Plans ................................................................................................... 17 Process of Ensuring Continual Risk Reduction Following the Implementation of Action Plans 17 Sharing of Lessons Learnt ..................................................................................................... 17 10 Equality Impact Assessment ............................................................................... 19 11 Monitoring Compliance with the Document ..................................................... 19 V.5 March 2012 Page 2 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 11.1 11.2 12 12.1 12.2 13 Process for Monitoring Compliance ..................................................................................... 19 Standards/Key Performance Indicators ................................................................................ 19 References .......................................................................................................... 19 Legislation ............................................................................................................................. 19 Guidance from Other Organisations ..................................................................................... 20 Associated Documentation ................................................................................ 21 Appendix A - Incident Reporting Timescales ................................................................ 22 Appendix B - Incident Reporting Form ......................................................................... 22 Appendix C - Guide to Incident Form Completion ....................................................... 22 Appendix D - Risk Grading Tool - 5x5 ........................................................................... 22 Appendix F - Grading and Timescales for Investigation ............................................... 24 Appendix G - List External Stakeholders....................................................................... 25 Appendix H - Action Learning Points ............................................................................ 28 Appendix I - Guidance on How to Write a Statement .................................................. 29 Appendix K - Template Document for the Reporting and Management of Incidents Including Serious Incidents ........................................................................................... 33 V.5 March 2012 Page 3 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Review and Amendment Log Version no. Type of change Date Description of change V.4 Annual review Mar 2011 Update to section 10 ‘References’ V.4 Amendment Mar 2011 Addition of amendment log Addition of example of definition Addition of examples of associated documents V.5 Amendment Mar 2012 Change to format including automated contents page Please Note the Intention of this Document This document has been developed with the aim of providing a model document template. However, any documentation subsequently produced must follow its own rules and include details of all the requirements set out in sections 1-11, where relevant. The organisation may use this template and adapt it to reflect procedures within the organisation or alternatively use a document already in existence. Whichever approach is used the organisation must ensure it is compliant with the minimum requirements of the relevant National Health Service Litigation Authority (NHSLA) Risk Management Standards. a To assist the organisation, areas have been identified in the margins where the section within the template document relates to the minimum requirements for the criterion in the relevant NHSLA Risk Management Standards. It is important that the document should follow any pre-existing guidance within the organisation in relation to style and format of documentation. Please note that a template document entitled An Organisation-wide Document for the Development and Management of Procedural Documents can be found on the NHSLA website which may provide the organisation with additional guidance. V.5 March 2012 Page 4 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 1 Introduction Serious incidents in healthcare are relatively uncommon but when they do occur the NHS has a responsibility to ensure that there are systemic measures in place for safeguarding people, property, NHS resources and reputation. This includes the responsibility to learn from these incidents in order to minimise the risk of them happening again. This section should introduce the importance of establishing a safety culture within an organisation; a reporting culture, which appreciates the significance of effective incident management. Incident reporting is a fundamental tool of risk management, the aim of which is to collect information about adverse incidents, including near misses, ill health and hazards, which will help to facilitate wider organisational learning. If incidents are not properly managed, they may result in a loss of public confidence in the organisation and a loss of assets. Incident reporting is more likely to take place in an organisation where there is a well developed safety culture and where there is strong leadership. This section should explain that the chief executive and directors (including non-executives) support open and transparent systems of patient and staff safety , and that it is unacceptable to prioritise other objectives at the expense of safety. The reporting and management of incidents will lead into the processes described in the organisation’s document for the investigation of incidents, complaints and claims, and the document for analysis and improvement following incidents, complaints and claims. (Template documents for these stages of the process are available on the NHSLA website). 2 Purpose This section should describe how the organisation intends to ensure that all incidents, whether they have caused actual harm, or were a near miss, are reported by staff in a timely manner. This section should describe how there is an intention to appropriately manage and investigate incidents, based on their severity, and to ultimately learn and make changes as a result of incidents, complaints and claims in order to improve safety for patients, staff, visitors and contractors. This section should include a statement regarding the non-punitive approach the organisation takes towards incident reporting. Organisations should consider the NPSA publications Seven Steps to Patient Safety (2004) and the National Framework for Reporting and Learning from Serious Incidents Requiring Investigation (2010). 3 Explanation of Terms This section should list and describe the meaning of the terms used within the context of the document. The following list is a guide only and not exhaustive: NHS funded services and care Healthcare that is partially or fully funded by the NHS, regardless of the location. Incident An event or circumstance which could have resulted, or did result, in unnecessary damage, loss or harm to patients, staff, visitors or members of the public. V.5 Serious incident requiring investigation March 2012 Page 5 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents A serious incident requiring investigation is defined as an incident that occurred in relation to NHS funded services and care resulting in one of the following: the unexpected or avoidable death of one or more patients, staff, visitors or members of the public; permanent harm to one or more patients, staff, visitors or members of the public, or where the outcome requires life saving intervention or major surgical/medical intervention, or will shorten life expectancy (this includes incidents graded under the NPSA definition of severe harm (Seven Steps, 2004, p100); a scenario that prevents, or threatens to prevent, a provider organisation’s ability to continue to deliver health care services, for example, actual or potential loss or damage to property, reputation or the environment; allegations of abuse; security incidents; adverse media coverage or public concern for the organisation or the wider NHS; or one of the core set of Never Events. Never Events Never Events are serious, largely preventable patient safety incidents that should not occur if the available preventative measures have been implemented. These are updated on an annual basis and currently include (DH 2011): V.5 wrong site surgery; wrong implant/prosthesis; retained foreign object post-operation; wrongly prepared high-risk injectable medication; maladministration of potassium-containing solutions; wrong route administration of chemotherapy; wrong route administration of oral/enteral treatment; intravenous administration of epidural medication; maladministration of insulin; overdose of midazolam during conscious sedation; opioid overdose of an opioid-naïve patient; inappropriate administration of daily oral methotrexate; suicide using non-collapsible rails; March 2012 Page 6 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents escape of a transferred prisoner; falls from unrestricted windows; entrapment in bedrails; transfusion of ABO-incompatible blood components; transplantation of ABO or HLA-incompatible organs; misplaced naso- or oro-gastric tubes; wrong gas administered; failure to monitor and respond to oxygen saturation; air embolism; misidentification of patients; severe scalding of patients; and maternal death due to post partum haemorrhage after elective caesarean section. Security incident From April 2010 NHS Protect introduced a Security Incident Reporting System. This was developed to provide a clearer picture of security incidents across the health service in England, locally and nationally. This is a key step towards building a safer NHS where people and property are better protected. SIRS coincides with the extended requirements for reporting to NHS Protect. The following security incidents must be reported using SIRS: any security incident involving physical assault of NHS staff; non-physical assault of NHS staff (including verbal abuse, attempted assaults and harassment); theft of or criminal damage (including burglary, arson, and vandalism) to NHS property or equipment (including equipment issued to staff); and theft of or criminal damage to staff or patient personal property arising from these types of security incident. Unexpected death Where natural causes are not suspected; local organisations should investigate these to determine if the incident contributed to the unexpected death. Permanent harm Harm directly related to the incident and not to the natural course of the patient’s illness or underlying conditions; defined as permanent lessening of bodily functions, including sensory, motor, physiological or intellectual. V.5 March 2012 Page 7 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Prolonged pain and/or prolonged psychological harm Pain or harm that a patient has experienced, or is likely to experience, for a continuous period of 28 days. Severe harm Any patient safety incident that appears to have resulted in permanent harm to one or more persons receiving NHS funded care. Major surgery A surgical operation within or upon the contents of the abdominal or pelvic, cranial or thoracic cavities, or a procedure which, given the locality, condition of patient, level of difficulty, or length of time to perform, constitutes a hazard to life or function of an organ, or tissue (if an extensive orthopaedic procedure is involved, the surgery is considered ‘major’). The NPSA has an anaesthetic e-form for reporting anaesthesia events that organisations can report on. The e-form can be found at: Link Abuse A violation of an individual’s human or civil rights by any other person or persons. Abuse may consist of single or repeated acts. It may be physical, verbal or psychological; it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he or she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm, or exploitation, of the person subjected to it. This is defined in No secrets: Guidance on developing and implementing multi-agency policies and procedures to protect vulnerable adults from abuse (DH 2000), and Working Together to Safeguard Children: A guide to inter-agency working states that abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by ‘inflicting harm’ or by failing to act to prevent harm (DCSF 2006, p37). Working days Days that exclude weekends and bank holidays (Run from 23:59 on the day the incident is raised to 23:59 on the day the incident is reported). a 4 Duties Give a brief overview of the roles, responsibilities and accountabilities for the implementation of the organisation’s process. This section should be a brief overview only and the details of the process for managing this should be incorporated within later sections of the document. The following list is a guide only and is not exhaustive: 4.1 Duties within the Organisation Some example responsibilities have been identified below; however, these should be considered within the context of the individual organisational structure. Chief Executive This section should state that the chief executive is ultimately accountable for the implementation of this organisation-wide process, and a reiteration of their nonpunitive stance should be included here. V.5 March 2012 Page 8 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Senior Manager Roles and responsibilities of the senior management and how their involvement with the incident should be documented. Line Manager The role to be taken by the line manager, including any immediate actions which need to be taken post incident, should be described including any documentation which needs to be completed. The organisation should set out who will inform the line manager and who else within the organisation needs to be contacted and when. There is a list of external stakeholders at Appendix G. Risk Manager/Equivalent Roles and responsibilities of the risk manager and how their involvement with the incident should be documented. All Staff Document the responsibly of all staff to report incidents in a timely manner. A cross reference may be required to the organisation’s document for supporting staff following a traumatic incident. 4.2 Committees and Groups with Overarching Responsibilities Trust Board For effective implementation of the Organisation-wide Document for the Reporting and Management of Serious Incidents there must be active support from the most senior members of the organisation. Organisations should detail how the chief executive and the nominated directors are to gain assurance that this document is being implemented within the organisation, and how they intend to be made aware of the serious incidents, and the more high frequency, low risk incidents. There must be effective cooperation at all levels of the organisation in order for this process to be successful. Committee with Overarching Responsibility for Risk Management Roles and responsibilities of the committee(s) with overarching responsibility for risk management should be documented. This should include how all incidents, nonclinical and clinical, are integrated and reported to the relevant committees; the committee’s role in ensuring actions are taken as a result of trend analysis; and the cascading of information throughout the organisation. The reporting and management of incidents will lead into the processes described in the organisation’s document for analysis and improvement following incidents, complaints and claims. (A template document is available on the NHSLA website). Responsibility for monitoring the completion of the action plans and the subsequent effectiveness of any risk reduction measures introduced should be included within this section. Inclusion/description of the terms of reference for this committee including accountability, responsibility, authority, membership (including co-opted members V.5 March 2012 Page 9 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents and deputies), the meeting schedule and quorum, etc. It is considered good practiceto date and sign the terms of reference and apply a review date. Other Committees/Groups with Responsibilities for Incident Management Many other groups/committees have a role in the management of incidents. This section will need to include the role of other corporate/organisation-wide committees, e.g. the training and education group, or health and safety committee, or more locally based groups, which are responsible for ensuring the lessons learnt organisationally are introduced into the service areas/departments. 5 Response, Communication and Notification 5.1 Immediate Response by the Organisation In all instances, the first priority for the provider organisation is to ensure the needs of individuals affected by the incident are attended to, including any urgent clinical care which may reduce the harmful impact. A safe environment should be re-established, all equipment or medication retained and isolated, and all relevant documentation copied and secured to preserve evidence to facilitate the investigation and learning. If there is a suggestion that a criminal offence has been committed, the organisation should contact the police. The organisation should give early consideration to the provision of information and support to patients, relatives and carers and staff involved in the incident. This section should include information regarding any support systems which are available to patients/relatives/visitors/contractors. The organisation should follow guidance provided in the ‘being open’ document. The needs and involvement of staff in the incident should also be considered. The NPSA’s Incident Decision Tree (NPSA 2008) resource can assist here. If the incident is a potential adult safeguarding concern, organisations should have established and robust local processes in place and a safeguarding alert raised. It is also important to identify where other agencies need to be brought into the management of a serious incident when required. Cross reference should be made to the list of external stakeholders at Appendix G. b 5.2 Reporting the Incident This section should set out the timescales involved with incident reporting: when the incident should be reported both to the immediate line manager and then centrally to the risk management department. This section should illustrate the need to grade the incident, what immediate actions should be taken and what documentation needs to be completed. The organisation could add the following to this document as appendices: the incident report form, a guide to incident form completion, the risk matrix, and the list of potentially reportable incidents. Reporting Timescales All identified serious incidents must be notified to the relevant bodies without delay. This section should set out who will be responsible for such reporting and how this will be achieved. There is a list of external stakeholders at Appendix G. V.5 March 2012 Page 10 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents This section should provide the details about the communication and notification processes to be followed by the organisation, particularly to the NPSA and to the Strategic Executive Information System (STEIS) or local serious incident reporting systems. In addition, some serious incidents require organisations to fulfil reporting requirements to other bodies as appropriate. Strategic Health Authorities (SHAs) may disseminate separate requirements for using STEIS or local serious incident reporting systems to complement this document. From 1st April 2010, as part of the registration requirements arising from the Health and Social Care Act 2008, organisations are required to notify the Care Quality Commission (CQC) about events that indicate or may indicate risks to ongoing compliance with registration requirements, or that lead or may lead to changes in the details about the organisation in the CQC's register. 5.3 Patient/Relative/Visitor/Contractor Communication and Support Communication with patients and/or their relatives, visitors or contractors will normally need to take place both pre and post investigation. This section should define who within the organisation is responsible for verbal/written communication; when communication is to take place; and how this information should be documented. This section should include information regarding any support systems which are available to patients/relatives/visitors/contractors. This communication needs to follow the principles of ‘being open’ and this information could be included within this document or there could be a clear cross reference to the organisation’s ‘being open’ document. 5.4 Internal Communication This section should describe who within the organisation needs to be informed of an incident at all levels, who is to inform them and the timescales which must be adhered to. c 5.5 External Stakeholder Notification Reporting Responsibilities NHS Organisations NHS organisations, including providers of community services, are accountable to commissioning bodies through contracting and commissioning arrangements. NHS organisations are also regulated by the CQC. This section should set out who will be responsible for such reporting and how this will be achieved. Foundation Trusts NHS Foundation Trusts and their board of directors are accountable to commissioning bodies through contracting and commissioning arrangements, and to their governors and members. Foundation Trusts are regulated by Monitor for compliance with their terms of authorisation. Serious incidents in Foundation Trusts should be reported to the lead commissioning body and must be reported to the NPSA. Foundation Trusts that breach or risk breaching their terms of authorisation are also required to report all serious incidents to Monitor. They are required to have adequate processes and procedures in place to identify, report and take appropriate action on a timely basis in relation to serious incidents, and to identify V.5 March 2012 Page 11 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents key stakeholders and inform these as appropriate. At the time of publication of this template document all serious patient safety incidents should be reported to the NPSA and to the STEIS or local serious incident reporting systems. In addition, some serious incidents require organisations to fulfil reporting requirements to other bodies as appropriate, as described in the information resource to support the reporting of serious incidents on the NPSA’s website. Independent Providers of NHS Care Non-NHS providers, including independent provider organisations and practitioners, are accountable to commissioning bodies through contracting and commissioning arrangements, and through national contracts. This section should set out who will be responsible for such reporting and how this will be achieved. 6 Communication with Staff 6.1 Communication Following an Incident Communication with staff may need to be both pre and post investigation. Staff personally involved in the incident itself and other staff within the organisation may need to be involved in discussions. This section should define who is responsible for this communication; when communication is to take place; and how this communication needs to be documented. The section should include information regarding any support systems which are available to staff. Cross reference could be made available to the organisation’s document for supporting staff. d 6.2 Process by which to Raise Concerns There is a need for staff to be aware of how to raise their concerns regarding near miss incidents; this information could be included within this document, or there could be a clear cross reference to organisational documents such as the whistle blowing or raising concerns procedures. 7 Media Involvement Communications are a vital element of supporting and delivering effective management of serious incidents. The organisation is responsible for ensuring that robust communications and media management arrangements are in place for both internal and external communication. In many cases serious incidents can lead to a high level of media attention and not only in the immediate aftermath. The management, investigation and learning from incidents can be triggers for media coverage for an extended period after the incident itself. The organisation should describe the media handling strategies in place which include the appropriate action to be taken in relation to serious incidents, including protocols with other local organisations and agencies on media handling and strategies for ongoing and longer term management of media coverage. This section should include the requirement for communication leads to work closely with the SHA communications professionals to agree appropriate media handling strategies, working alongside the relevant colleagues responsible for the wider management of the incident. Responsibility for briefing the Department of Health Ministerial Briefing Unit or Media Centre rests with the SHA; therefore they need to be accurately briefed in a timely manner. V.5 March 2012 Page 12 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents In forensic/criminal cases, the police lead all communications with the media and liaise with the relevant agencies where they have involvement in the incident. The organisation should describe how the problem will be understood and how steps being taken to put it right in order to provide reassurance that the risks of the same thing happening again have been minimised. This is the key principle that should inform all public and media contact. Local judgment should be applied in deciding when help lines and counselling are necessary; how patients are contacted and when to hold press briefings on and off the record, as well as press conferences. The section should describe how decisions will be taken between the communications professional at the SHA in consultation with the serious incident team and the organisation. Generally there are three communication categories which will determine how a serious incident may be handled: the media is unaware of a serious incident; the media is unaware of a serious incident but should be informed so it can help with the handling of the incident by notifying the general public and/or section of the public of, for example, the need to come forward for re-testing following a screening programme incident; or the media is aware of an incident first and in this case the SHA/commissioning body/provider organisation may have only learned of a problem because it has been publicised by the media or the handling of an ongoing serious incident has ‘leaked’ into the public domain. 7.1 Media Unaware of Serious Incident It is essential that a holding statement for the media is prepared as soon as possible so that the organisation is prepared. This will require revision depending upon how well a subsequent media inquiry is informed. Some types of incident such as those involving screening programmes can involve contacting patients for recall or reassurance. Where this is the case all attempts should be made to contact patients before the media is alerted (where the media is unaware of the serious incident or where you have to seek the media's assistance), as long as it does not compromise patient safety in any way. However, contacting patients hugely increases the chances of the serious incident reaching the public domain and the media ahead of planned management. Prior to making contact with patients there should ideally be a reactive media handling strategy in place. However, any delay in such circumstances should not place patients at any increased risk of harm. This section should document the process for informing patients/staff/relatives and other persons (i.e. contractors involved in or affected by the event) before the media, and who within the organisation will be tasked with dealing with and coordinating such communications. Another source of information reaching the public domain is from health care staff. Such instances may be accidental or deliberate. For example, if staff believe managers are not taking seriously their concerns about a serious incident or if they do not seem to be acting on their warnings then there is a high likelihood of the story ‘leaking’ to the media. Therefore the organisation should document how health care managers will: V.5 March 2012 Page 13 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 7.2 keep staff informed; show they are taking their concerns seriously and acting upon them; and include staff so they have ownership and understand the need to observe patient and service confidentiality; the former is readily accepted by staff, but the latter only if they understand and believe that by going to the press they will cause more harm than good for patients and the service. Media Unaware but Proactive Media Handling Necessary A proactive media approach should be followed where time and wider public health concerns can only be addressed through this route, for example, after the loss of personal data records where the only way a large number of patients can be contacted is by public appeal. This section should set out how communication leads will ensure they know the extent of the problem; explain why the media's assistance is needed; how those affected will be supported; and what will be or has been done to ensure there will be no repeat of the incident: 7.3 understand the problem; put it right; reassure; and robust and secure feedback channels (help lines if appropriate). Media Aware of Serious Incident Those directly involved in the incident, including the investigation team and head of communications, need time, space and support and it is the role of communication leads to provide this space whilst keeping journalists informed. This includes planning for the next stage, posing solutions and recommended handling to help support investigation and use the team most effectively. Under these circumstances the need to rapidly establish the facts and fully understand the extent of the problem and its cause is even more essential. It is important to keep the public and media informed and share communications with partner agencies in advance of public information release, whilst balancing the needs of the affected people, staff and patients. The organisation should describe how staff will be kept informed so they understand why and how the organisation is acting, their role and ownership in fixing the problem and the organisation’s communication plans. 8 Hotline Arrangements This section should provide a clear explanation of how the organisation will manage an incident which has affected a large number of individuals who may need either to be contacted by, or who may need to contact, the organisation. The section could cover: V.5 management responsibility; phone lines; March 2012 Page 14 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 9 staffing; capacity to manage calls over time; documentation; record keeping; IT and postal arrangements; and e-form. Incident Investigation This section should detail the process of investigation to be conducted by the organisation, and a description of how the organisation intends to monitor the completion of action plans and the subsequent sharing of lessons learnt. The organisation may refer to a separate investigation procedure for incidents, complaints and claims. A template document, An Organisation-wide Document for the Investigation of Incidents, Complaints and Claims is available. 9.1 Incident Grading and Appropriate Levels of Investigations This section should describe how different grades of incidents will require different depths of investigation, and how various levels of management may undertake them. The section should include the need for re-grading the incident post investigation. This section should describe (and cross reference to the appropriate document) the process for getting any significant risks onto the organisation’s risk register and the process for getting lesser risks onto local risk registers. Appendix E is a guide to the serious incident grades developed by the NPSA, timescales and monitoring requirements. Grading should be agreed by the accountable SHA and provider organisations on an individual case by case basis and with advice from specialist sources where appropriate. It is recommended that investigations follow the NPSA guidance and identify both active (e.g. acts and omissions by staff) and latent (e.g. organisational or environmental issues) failures. If only active failures are identified the resulting solutions are unlikely to maintain sustainable prevention. 9.2 Responsibility for Investigation This section should describe who within the organisation will have responsibility for the investigation of incidents of all severity. Organisations should refer to the NPSA’s Seven Steps to Patient Safety - Your Guide to Safer Patient Care (2004). There are likely to be training requirements, which should be stated, or cross referenced to the organisational training needs analysis. Where the investigation involves more than one organisation, anything uncovered by local investigations that may be pertinent, e.g. timelines, care/service delivery problems and causal factors, should be communicated to the agreed lead organisation to ensure a full analysis of the incident and root causes to be determined. Allegations of abuse should always be referred immediately to local multi-agency safeguarding arrangements for adults and children and a safe guarding alert raised. Safeguarding investigations are coordinated by those arrangements and should not begin independently of them. V.5 March 2012 Page 15 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 9.3 Responsibility for Causal Factor Analysis This section should include a description of who undertakes this analysis; how often it should take place; which committees the analysis will be submitted to; and how this information ultimately informs the board. This analysis should be both qualitative and quantitative in nature, and discuss any trends that have been identified, e.g. if there has been a growing trend in communication issues, has this been due to poor written information, poor verbal information, communication between professional groups, communication between different sites or communication with other neighbouring organisations? 9.4 Responsibility for Causal Factor Analysis Post Investigation The organisation will uncover a number of causal factors during an investigation, which will undoubtedly lead to the identification of trends. For example: communication, training, equipment, etc; this analysis could be extremely useful for the organisation. Included within this section should be the responsibility for this trend analysis and how often it will be required to take place. It may also be useful to describe how this information will be collated and disseminated throughout the organisation. This information could be included within this document, or there could be a clear cross reference to the organisational document which describes the process for ensuring a systematic approach to the analysis of incidents, complaints and claims on an aggregated basis. 9.5 Involving Patients and their Families in Investigations into Serious Incidents The level of patient/family involvement clearly depends on the nature of the incident and the patient or family’s wish to be involved, but provider organisations should have an organisational Being open document in place, which staff are aware of and the principles of which are in current use. Unless there are specific indications to the contrary or the patient/their family requests other arrangements, these issues should be covered in a series of ongoing open discussions between the staff providing the patient’s care and the patient and/or their relatives or carers. Note: Patients and families have the right to request information held by public authorities (Freedom of Information Act 2000). This includes access to medical records and any associated documentation (The Re-use of Public Sector Information Regulations SI 2005/1515). This should be considered when writing incident investigation reports and actions. 9.6 Involvement of Relevant Stakeholders This section should describe the possible involvement of external agencies such as the Health and Safety Executive (HSE), the Medicines and Healthcare products Regulatory Agency (MHRA), the police or the Environmental Health Agency (EHA) etc. They may be needed to help investigate certain incidents which may be outside the expertise of those within the organisation. This section should define whose responsibility it is to contact these agencies, and when their involvement may be requested. It may also be necessary, if an incident occurs across a number of organisational boundaries, to work together in a joint investigation, and this section could be used to describe how such investigations may be managed. Cross reference should be made to Appendix G, the list of external stakeholders. V.5 March 2012 Page 16 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 9.7 Root Cause Analysis (RCA) and Investigation Report This section should describe how the root cause analysis and investigation report will be compiled, or provide a cross reference to the organisation’s root cause analysis document. An investigation executive summary (using the template in Appendix J) should be published for each serious incident. It should include a précis of the incident and investigation and be fully anonymised to preserve confidentiality of the people involved and the ward/team/unit/hospital and provider organisation. This will enable the executive summary to be widely shared. The NPSA’s Root Cause Analysis (RCA) investigation report writing templates (2010) could be used. 9.8 Recommendations and Action Planning This section should document the need for recommendations to be made post investigation, and for a detailed action plan to be produced. Action plans should include persons responsible and the date for completion. 9.9 Monitoring of Action Plans In this section the organisation should include a description of how action plans produced as a result of investigations are monitored in order to ensure their completion. This may be a specific responsibility for a committee or for nominated individuals. 9.10 Process of Ensuring Continual Risk Reduction Following the Implementation of Action Plans This section should describe how the organisation will ensure that those risk reduction measures taken post investigation are continuing to be effective, and that risk has not been transferred unwittingly. 9.11 Sharing of Lessons Learnt The sharing of the lessons learnt post investigation is a critical part of incident management. Learning from patient safety incidents is a collaborative, decentralized and reflective process that draws on experience, knowledge and evidence from a variety of sources. The learning process is a process of change evidenced by demonstrable, measurable and sustainable change in knowledge, skills, behaviour and attitude. Learning can be demonstrated at organisational level by changes and improvements in process, policy, systems and procedures relating to patient safety within healthcare organisations. Individual learning can be demonstrated by changes and improvements in behaviour, beliefs, attitudes and knowledge of staff at the front line of healthcare delivery. What Constitutes Learning Learning following an incident should be linked to safety related policy, practice and process issues raised by the incident. Examples of learning are given below: V.5 solutions to address incident root causes which may be relevant to other teams, services and provider organisations; March 2012 Page 17 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents identification of the components of good practice which reduced the potential impact of the incident, and how they were developed and supported; systems and processes that allowed early detection or intervention which reduced the potential impact of the incident; lessons from conducting the investigation which may improve the management of investigations in future; and documentation of identification of the risks, the extent to which the risks have been reduced, identified and how this is measured and monitored. Learning points should be grouped or themed to help the reader(s) identify those points applicable to their team, service, speciality, division or wider organisation as depicted in Appendix H - Action Learning Points. Summary Points for Dissemination of Learning from a Serious Incident This section should include a clear description of how this sharing of information is to take place, and how findings of investigations are disseminated throughout the organisation. It may also be good practice to include how lessons could be shared across organisational boundaries. The organisation may include a cross reference to the organisational document which describes the process for encouraging learning and promoting improvements in practice, based on individual and aggregated analysis of incidents, complaints and claims. Identifying Issues which may be of National Significance Investigations may identify issues of national significance or where the dissemination of national learning is appropriate. Organisations such as the NPSA, MHRA, HPA, HSE, etc. have review, response and alert mechanisms for urgent incidents. As already stated, relevant incidents should be notified to these bodies as part of the serious incident reporting process and provider organisations should subsequently share findings from investigations with these bodies where issues of potential national learning for wider sharing are identified. Learning from Serious Case Reviews (SCR) Executive representatives from the NHS are part of the local Safeguarding Adults Board (SAB) arrangements in each area and they are responsible for ensuring that communication between the SAB and the NHS Board is maintained. Learning lessons is the prime rationale of SCRs, and SABs are responsible for commissioning each SCR; sharing the learning across all organisations; and monitoring at agreed review periods whether the lessons have been taken on board. The SAB is responsible for ensuring that they receive regular progress reports on a commissioned SCR and to take action if the delay appears unreasonable. NHS organisations in partnership with the SAB should have local policies for implementing the findings from SCR, a process to report to their own boards, and action plans to implement and monitor changes in practice. V.5 March 2012 Page 18 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 10 Equality Impact Assessment The organisation should identify who will undertake the Equality Impact Assessment which is required to consider the needs and assess the impact of this document in accordance with the Organisation-wide Document for the Development and Management of Procedural Documents. The Equality Impact Assessment Tool found at Appendix E of the Organisationwide Document for the Development and Management of Procedural Documents could be completed and form part of the body of the document, but as a minimum a statement should be included within the document to demonstrate that an Equality Impact Assessment has been carried out and that the document does not discriminate, highlighting any areas of good practice or risk areas requiring attention. e 11 Monitoring Compliance with the Document 11.1 Process for Monitoring Compliance This section should identify how the organisation plans to monitor compliance with the Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents. As a minimum it should include the review/monitoring of all the minimum requirements within the NHSLA Risk Management Standards. The following list is a guide to issues which could be considered within this section and should be added to where appropriate: 11.2 Who will perform the monitoring? When will the monitoring be performed? How are you going to monitor? What will happen if any shortfalls are identified? Where will the results of the monitoring be reported? How will the resulting action plan be progressed and monitored? How will learning take place? Standards/Key Performance Indicators This section could contain auditable standards and/or key performance indicators (KPIs) which may assist the organisation in the process for monitoring compliance. 12 References This section should contain the details of any reference materials reviewed in the development of the procedural document. Listed below are some useful sources of reference material: V.5 12.1 Legislation Health and Safety (Consultation with Employees) Regulations 1996 SI 1996/1513 Public Interest Disclosure Act 1998 March 2012 Page 19 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents V.5 12.2 Guidance from Other Organisations Department of Health website offers further information and resources at www.dh.gov.uk Health Service Circular 1999/198 The Public Interest Disclosure Act 1998: Whistle blowing in the NHS (1999) Memorandum of understanding: Investigating patient safety incidents involving unexpected death or serious untoward harm: A protocol for liaison and effective communications between the National Health Service, Association of Chief Police Officers and Health and Safety Executive (2004) Independent investigation of adverse events in mental health services (2005) Safety First. A report for patients, clinicians and healthcare managers (2006) The NHS Constitution: The NHS belongs to us all (2010) General Medical Council (GMC) (2008) ‘Raising concerns about patient safety: Guidance for doctors’ GMC website page Health and Safety Executive website provides further information and resources at www.hse.gov.uk ‘What is RIDDOR?’ HSE website Work Related Death P16 Protocol and Guidance (2003) Consulting employees on health and safety: A brief guide to the law (2008) Involving your workforce in health and safety: Good practice for all workplaces (2008) House of Commons. (2009) House of Commons Health Committee: Patient Safety: Sixth Report of Session 2008-09, Volume I National Patient Safety Agency (NPSA) website offers further information and resources on incident reporting at http://www.npsa.nhs.uk/ ‘Incident decision tree’ Online tool Seven Steps to Patient Safety in Primary Care Trusts (2006) Briefing Issue 161: Act on reporting (2008) National Framework for Reporting and Learning from Serious Incidents Requiring Investigation (2009) National Reporting and Learning Service (NRLS) Data Quality Standards: Guidance for Organisations Reporting to the Reporting and Learning System (RLS) (2009) Patient Safety Alert: Update WHO Surgical Safety Checklist (2009) March 2012 Page 20 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 13 Questions are the answer! Seven questions every board member should ask about patient safety (2009) Medical Error: What to do if things go wrong: A guide for junior doctors (2010) Never Events: Framework – Update for 2010/11: Process and action for Primary Care Trusts (2010) National Screening Committee, NHS Cancer Screening Programmes (2010) Managing Serious Incidents in National Screening Programmes NHS Security Management Service (2010) Security Incident Reporting System Patient Safety First (2009) The ‘How to Guide’ for Implementing Human Factors in Healthcare Associated Documentation This section should provide a cross reference to any other related organisational procedural document(s). The following list is a guide only and is not exhaustive: V.5 Complaints management Claims management Learning Being open Risk management Investigation and root cause analysis Supporting staff March 2012 Page 21 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix A - Incident Reporting Timescales Appendix B - Incident Reporting Form Appendix C - Guide to Incident Form Completion Appendix D - Risk Grading Tool - 5x5 Organisation to develop V.5 March 2012 Page 22 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix E - Serious Incident Grading Tool Grade 0 Action required: Notification only - it is unclear if a serious incident has occurred. The provider organisation must update the commissioning body/SHA with further information within three working days of a grade 0 incident being notified. If within three working days it is found not to be a serious incident, it can be downgraded with the agreement of the accountable SHA/commissioning body. If a serious incident has occurred it will be regraded as a grade 1 or 2. Grade 1 Action required: Monitoring required: Examples: Commissioning bodies will Local monitoring Examples of cases: ‐ monitor the case and report The commissioning body Mental Health - deaths in findings, recommendations and/or SHA will close the the community and associated action plans to incident when it is satisfied the HCAI outbreaks the SHA. investigation, Unavoidable/unexplained recommendations and action death SHA will monitor progress on plan are satisfactory, and local Mental health a quarterly basis with the monitoring arrangements are attempted suicides as commissioning body unless in place and working inpatients earlier discussion is required efficiently. Ambulance services or the serious incident is re- Publish incident details within missing target for arrival graded. Annual Reports. resulting in death/severe harm to patient Comprehensive Investigation Timescales:‐ Data loss and information Root Cause Analysis (RCA) Up to 45 working days/9 security (DH Criteria level required Level 2 Investigation weeks from the date the incident 2) is notified to the commissioning Grade 3 pressure ulcer body/SHA. develops Poor discharge planning causes harm to patient Grade 2 Action required: Monitoring required: Example of cases: Case will be monitored by the SHA/commissioning body Maternal deaths SHA/commissioning body/LA Incidents involving an Inpatient suicides in conjunction with the independent investigation or (including following provider organisation. inquiry or those considered absconsion)* high risk will continue to be Data loss and information The SHA will review findings, monitored by the security (DH Criteria level recommendations and SHA/commissioning body or LA 3-5) associated action plans. until evidence is provided that Never Events each action point has been Accusation of For ‘Never Events’, the implemented. Incidents physical/sexual commissioning body will be involving adult or child abuse misconduct or harm is obliged to monitor overall are referred to local made numbers and report these in safeguarding arrangements. Homicides following its annual reporting Publish quarterly reports. recent contact with arrangements. mental health services* Timescales: Comprehensive Investigation For Independent Investigations * Mental Health incidents (RCA Level 2 investigation) allow up to 26 weeks/6 months for should refer to DH guidance: (as above) or Independent completion of the investigation. Independent investigation of Investigation (RCA Level 3 Extensions can be granted on an adverse events in mental Investigation) individual case by case basis by the health services (2005). SHA/commissioning body. *Working day ‐ Days that exclude weekends and bank holidays (Run from 23:59 on the day the incident is raised to 23:59 on the day the incident is reported) V.5 March 2012 Page 23 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix F - Grading and Timescales for Investigation Incident grading Investigation type Timescales for completion of investigation Grade 1 Comprehensive Investigation (RCA Level 2 Investigation) Conducted to a high level of detail, including all elements of a thorough and credible investigation. Conducted by a multidisciplinary team, or involves experts/expert opinion/independent advice or specialist investigator(s). Conducted by staff not involved in the incident, locality or directorate in which it occurred. Overseen by a director level chair or facilitator. Led by person(s) experienced and/or trained in RCA, human error and effective solutions development. Includes patient/relative/carer involvement and should include an offer to patient/relative/carer of links to independent representation or advocacy services. May require management of the media via the organisation’s communications department. Includes robust recommendations for shared learning, locally and/or nationally as appropriate. Results in full report with an executive summary and appendices. Comprehensive Investigation (RCA Level 2 Investigation) (As above) or Independent Investigation (RCA Level 3 Investigation) Must be commissioned and coordinated by the Commissioning body or SHA and independent to the provider organisation service(s) and organisation(s) involved in the incident, for independent investigations only. Commonly considered for incidents of high public interest or attracting media attention. An independent investigation must be conducted for mental health homicides (where there has been recent contact with mental health services) that meet Department of Health Guidance. Should be conducted where Article 2 of the European Convention on Human Rights is, or is likely to be, engaged. Up to 45 working days/9 weeks from the date the incident is notified to the commissioning body/SHA. Grade 2 V.5 March 2012 Comprehensive investigations can be completed more quickly if the provider organisation wishes and extensions beyond the 45 days can be agreed between the provider organisation and commissioning body/SHA. Up to 60 working days/12 weeks from the date the incident is notified to the commissioning body/SHA. Comprehensive investigations can be completed more quickly if the provider organisation wishes and extensions beyond the 60 days can be agreed between the provider organisation and commissioning body/SHA. For independent investigations allow up to 26 weeks/6 months for completion of the investigation. Page 24 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix G - List External Stakeholders The document must detail which other external bodies need to be informed of/involved in the actual investigation of the incident. The following list is a guide only and is not exhaustive: Department of Health Patient Safety Policy Branch Department of Health NHS Contracting Welsh Assembly Government Other NHS organisations Strategic Health Authorities Care Quality Commission Monitor National Patient Safety Agency (NPSA) NHS Litigation Authority (NHSLA) Medicines and Healthcare Products Regulatory Agency (MHRA) Health and Safety Executive (HSE) Area Child Protection Committee Health Protection Agency NHS Confederation NHS Business Services Authority NHS Protect Connecting for Health National Blood Service Audit Commission Confidential Enquiries & Inquiries NPSA National Clinical Assessment Service Independent Healthcare Advisory Service NHS Information Centre for Health and Social Care NPSA National Research Ethics Service National Screening Programmes SHOT (Serious Hazards of Transfusion) The police HM Coroner Social services CORESS (Confidential Reporting System for Surgery) V.5 March 2012 Page 25 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Legal advisors Medical defence organisations Incidents Occurring Across the Boundaries of Two or More Commissioning Bodies Where a serious incident crosses the boundary of two or more commissioning bodies, the commissioning bodies concerned will liaise to ensure each other is notified, a lead commissioning body is identified and a timescale is locally agreed. Incidents Involving More than one Provider Organisation If more than one organisation is involved in a serious incident, the organisation which identified the incident can make the initial notification having first made contact, wherever possible, with the organisation where it originated. The lead organisation must be identified and agreed (with clear responsibilities) at this point with the other organisations involved. The named lead/point of contact should be clearly identified to the SHA/commissioning body. NHS organisations have a primary responsibility to investigate and take preventative action when things go wrong in order to ensure the safety and well-being of patients and staff so all stakeholders have an obligation to collaborate. The only exception to this may be when dealing with a ‘safeguarding’ alert. Incidents Involving the Health & Safety Executive (HSE) and the Police The Memorandum of understanding: Investigating patient safety incidents involving unexpected death or serious untoward harm: A protocol for liaison and effective communications between the National Health Service, Association of Chief Police Officers and Health and Safety Executive published by the Department of Health in February 2006 provides a protocol for liaison and effective communication between the NHS, the Health & Safety Executive (HSE) and the Association of Chief Police Officers with regard to investigating patient safety incidents (unexpected death or serious untoward harm). Reporting of Serious Incidents to the Care Quality Commission Providers are required to notify the Care Quality Commission (CQC) either directly or via other bodies, of certain categories of incidents. The types of incident and reporting arrangements are defined in The Health and Social Care Act 2008 (Registration of Regulated Activities) Regulations 2009 SI 2009/660 and accompanying guidance about compliance. Independent Healthcare Provider Organisations and Practitioners A serious incident involving a patient in receipt of NHS funded care provided by an independent sector provider organisation must be notified by the NHS provider organisation to the relevant bodies as follows: V.5 March 2012 Page 26 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents National Contracts In the case of an independent sector provider organisation responsible for providing health care services under national contract, all serious incidents should be reported directly to: the lead commissioning/sponsoring body; NHS Contracting at the Department of Health; where appropriate, to comply with local safeguarding arrangements; Care Quality Commission (CQC). The commissioning body will report the incident to the SHA and the NPSA. Only serious incidents should be reported in accordance with the above requirements. However, independent providers of health care may also be required to report other types of incident to their lead commissioning body as part of their NHS contract or to other bodies as required in national legislation. Local Contracts In the case of an independent sector provider organisation responsible for providing health care services under local contract, all serious incidents are reported directly to the lead commissioning/sponsoring body (and where appropriate, to local safeguarding arrangements). The commissioning body will report the incident to the SHA through an agreed, secure protocol. If the independent sector provider organisation is registered with the CQC all serious incidents involving patients are also required to be reported by the provider organisation to the CQC. Where a serious incident from an independent sector provider organisation is discovered in the first instance by an NHS organisation, it should be immediately reported to the independent sector service provider organisation concerned. The only exception to this would be where the incident is or may be abuse, in which case local safeguarding procedures should be followed. The independent sector provider organisation is then required to report the adverse incident in line with their contractual obligations. The NHS organisation concerned should also inform the lead commissioning/sponsoring body about the incident. Subsequently, agreement should be reached between the parties about who leads the investigation. V.5 March 2012 Page 27 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix H - Action Learning Points Responsibilities for sharing learning With whom Example of communication Local and Organisation Learning Provider organisation(s) where the incident occurred Local: Patient and their family/carers directly involved in the incident where appropriate Staff directly involved in the incident Similar services/specialities to the service involved in the incident Organisational: Other departments/divisions for lessons with wider organisational applicability Across the organisation by improvements in process/policy and systems NPSA and other bodies with a remit for safety and serious incidents (MHRA, HPA, CfH, CFSMS, CQC etc) Professional networks, bodies and associations V.5 As appropriate: All relevant health care sectors and organisations Professional networks, bodies and associations Manufacturers and commercial enterprises International safety and quality networks and partners as appropriate Other bodies with a remit for safety and serious incidents Members Other networks and associations March 2012 Meetings with patients and their families Presentations at staff meetings Team meetings E‐bulletins and Newsletters Intranet site Public web site Public Board Papers Notice boards Email Internal alert systems Risk and Governance Committee Meeting minutes Risk management, incident reporting and investigation training courses (e.g. use of case studies) Central Alerting System (CAS), Chief Executive Bulletin, CMO Bulletin, etc Conferences, seminars and workshops Alerts, guidance, information, newsletters E‐networks Local organisation liaison/link officers Professional networks, bodies and associations E‐networks Letters to members Newsletters and bulletins Educational meetings Page 28 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix I - Guidance on How to Write a Statement Organisation to develop V.5 March 2012 Page 29 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix J - Investigation Report: NPSA Concise Investigation Report Template (2010). A Comprehensive and Independent Investigation Report Template is also available on the NPSA website: www.npsa.nhs.uk Root Cause Analysis Investigation Report Incident description and consequences Incident description: Incident date: Incident type: Specialty: Actual effect on patient: Actual severity of the incident: Level of investigation Level 1 – Concise investigation Involvement and support of patient and relatives Add text here FINDINGS: Detection of incident Add text here Care and service delivery problems Add text here Contributory factors Add text here Root causes Add text here Lessons learned Add text here CONCLUSIONS: Recommendations Add text here V.5 March 2012 Page 30 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Arrangements for Shared Learning Add text here Author and Job Title Add text here Report Date Chronology (timeline) of events Date & Time Event See also ‘Types of Preventative Actions Planned’ tool at www.npsa.nhs.uk/rca Action Plan Action 1 Action 2 Action 3 Root CAUSE EFFECT on Patient Recommendation Action to Address Root Cause Level for Action (Org, Direct, Team) Implementation by: Target Date for Implementation Additional Resources Required (Time, money, other) Evidence of Progress and Completion Monitoring & Evaluation Arrangements Sign off - action completed date: V.5 March 2012 Page 31 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents See also ‘Types of Preventative Actions Planned’ tool at www.npsa.nhs.uk/rca Action Plan Action 1 Action 2 Action 3 Sign off by: V.5 March 2012 Page 32 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Appendix K - Template Document for the Reporting and Management of Incidents Including Serious Incidents NHS Trust An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Version: Ratified by: Date ratified: Name of originator/author: Name of responsible committee/individual: Name of executive lead: Date issued: Review date: Target audience: V.5 March 2012 Page 33 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents Contents 1 Introduction ........................................................................................................... 36 2 Purpose .................................................................................................................. 36 3 Explanation of Terms ............................................................................................. 36 4 Duties ..................................................................................................................... 36 4.1 4.2 Duties within the Organisation ............................................................................................. 36 Committees and Groups with Overarching Responsibilities ................................................ 36 Response, Communication and Notification ......................................................... 36 5 5.1 5.2 5.3 5.4 5.5 Immediate Response by the Organisation ............................................................................ 36 Reporting the Incident .......................................................................................................... 36 Patient/Relative/Visitor/Contractor Communication and Support ...................................... 36 Internal Communication ....................................................................................................... 36 External Stakeholder Notification ......................................................................................... 36 Communication with Staff ..................................................................................... 36 6 6.1 6.2 Communication Following an Incident ................................................................................. 36 Process by which to Raise Concerns ..................................................................................... 37 Media Involvement ................................................................................................ 37 7 7.1 7.2 7.3 Media Unaware of Serious Incident ..................................................................................... 37 Media Unaware but Proactive Media Handling Necessary .................................................. 37 Media Aware of Serious Incident .......................................................................................... 37 8 Hotline Arrangements ........................................................................................... 37 9 Incident Investigation ............................................................................................ 37 9.1 9.2 9.3 9.4 9.5 9.6 9.7 9.8 9.9 9.10 9.11 Incident Grading and Appropriate Levels of Investigations .................................................. 37 Responsibility for Investigation............................................................................................. 37 Responsibility for Causal Factor Analysis .............................................................................. 37 Responsibility for Causal Factor Analysis Post Investigation ................................................ 37 Involving Patients and their Families in Investigations into Serious Incidents ..................... 37 Involvement of Relevant Stakeholders ................................................................................. 37 Root Cause Analysis (RCA) and Investigation Report............................................................ 37 Recommendations and Action Planning ............................................................................... 37 Monitoring of Action Plans ................................................................................................... 38 Process of Ensuring Continual Risk Reduction Following the Implementation of Action Plans 38 Sharing of Lessons Learnt ..................................................................................................... 38 10 Equality Impact Assessment ............................................................................... 38 11 Monitoring Compliance with the Document ..................................................... 38 V.5 March 2012 Page 34 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 11.1 11.2 12 12.1 12.2 13 Process for Monitoring Compliance ..................................................................................... 38 Standards/Key Performance Indicators ................................................................................ 38 References .......................................................................................................... 38 Legislation ............................................................................................................................. 38 Guidance from Other Organisations ..................................................................................... 38 Associated Documents ....................................................................................... 38 Appendix A Incident Reporting Timescales.............................................................. 38 Appendix B Incident Reporting Form (organisation’s own) ..................................... 38 Appendix C Guide to Incident Form Completion ..................................................... 38 Appendix D Risk Grading Tool - 5x5 (organisation’s own) ....................................... 38 Appendix E Serious Incident Grading Tool (organisation’s own) ............................ 38 Appendix F Grading and Timescales for Investigation (organisation’s own) .......... 38 Appendix G List of External Stakeholders ................................................................ 38 Appendix H Action Learning Points .......................................................................... 39 Appendix I Guidance on How to Write a Statement .............................................. 39 Appendix J Investigation Report: Concise Investigation Report Template............. 39 Appendix K Checklist for the Review and Approval of Procedural Documents ...... 39 Appendix L Version Control Sheet ........................................................................... 39 Appendix M Plan for Dissemination .......................................................................... 39 Appendix O Equality Impact Assessment Tool ......................................................... 39 Examples of the Checklist for the Review and Approval of Procedural Documents, Version Control Sheet, Plan for Dissemination and the Equality Impact Assessment Tool can all be found within the Organisation-wide Document for the Development and Management of Procedural Documents on the NHSLA website. Appendix B in the Organisation-wide Document for the Development and Management of Procedural Documents contains a flowchart to assist with the process for the creation and implementation of procedural documents. Review and Amendment Log Version no. V.5 Type of change Date March 2012 Description of change Page 35 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 1 Introduction 2 Purpose 3 Explanation of Terms 4 Duties 5 6 4.1 Duties within the Organisation 4.2 Committees and Groups with Overarching Responsibilities Response, Communication and Notification 5.1 Immediate Response by the Organisation 5.2 Reporting the Incident 5.3 Patient/Relative/Visitor/Contractor Communication and Support 5.4 Internal Communication 5.5 External Stakeholder Notification Communication with Staff 6.1 V.5 Communication Following an Incident March 2012 Page 36 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 6.2 7 Process by which to Raise Concerns Media Involvement 7.1 Media Unaware of Serious Incident 7.2 Media Unaware but Proactive Media Handling Necessary 7.3 Media Aware of Serious Incident 8 Hotline Arrangements 9 Incident Investigation V.5 9.1 Incident Grading and Appropriate Levels of Investigations 9.2 Responsibility for Investigation 9.3 Responsibility for Causal Factor Analysis 9.4 Responsibility for Causal Factor Analysis Post Investigation 9.5 Involving Patients and their Families in Investigations into Serious Incidents 9.6 Involvement of Relevant Stakeholders 9.7 Root Cause Analysis (RCA) and Investigation Report 9.8 Recommendations and Action Planning March 2012 Page 37 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents 9.9 Monitoring of Action Plans 9.10 Process of Ensuring Continual Risk Reduction Following the Implementation of Action Plans 9.11 Sharing of Lessons Learnt 10 Equality Impact Assessment 11 Monitoring Compliance with the Document 12 13 V.5 11.1 Process for Monitoring Compliance 11.2 Standards/Key Performance Indicators References 12.1 Legislation 12.2 Guidance from Other Organisations Associated Documents Appendix A Incident Reporting Timescales Appendix B Incident Reporting Form (organisation’s own) Appendix C Guide to Incident Form Completion Appendix D Risk Grading Tool - 5x5 (organisation’s own) Appendix E Serious Incident Grading Tool (organisation’s own) Appendix F Grading and Timescales for Investigation (organisation’s own) Appendix G List of External Stakeholders March 2012 Page 38 of 39 An Organisation-wide Document for the Reporting and Management of Incidents Including Serious Incidents V.5 Appendix H Action Learning Points Appendix I Guidance on How to Write a Statement Appendix J Investigation Report: Concise Investigation Report Template Appendix K Checklist for the Review and Approval of Procedural Documents Appendix L Version Control Sheet Appendix M Plan for Dissemination Appendix O Equality Impact Assessment Tool March 2012 Page 39 of 39